3 9004 01515875 8
NORTH SHORE RAILWAY,
FURTHER STATEMENT OF FACTS.
WITH A SUPPLEMENT.
By SILAS SEYMOUR,
Genkral Consulting Engineer.
QUEBEC, FEBRUARY 17th & 20th 1877.
NORTH SHORE RAILWAY,
FURTHER STATEMENT OF FACTS,
IN RELATION TO CERTAIN
MATTERS IN DIFFERENCE
Between THOMAS McGREEVY, Contractor,
SILAS SEYMOUR, General Consulting Engineer.
WITH A SUPPLEMENT
" The cry is, still they come 11 "
QUEBEC. FEBRUARY 17th & 20th 1877.
Digitized by the Internet Archive
NORTH SHORE RAILWAY
FURTHER STATEMENT OF FACTS
In relation to matters in difference betwee?i Silas
Seymour, General Consulting Engineer, and Thomas
McGreevy, Contractor for the North Shore Railway.
On the 10th of May, 1876, I published, in pamphlet
form, a " Statement of Facts, " in relation to certain " Special
Agreements, ' ; between Mr. McGreevy and myself, which
had been entered into during the summer of 1875.
The first of these .Agreements, dated June 21st, 1875,
had reference to my obtaining outside parties, who would
either furnish Mr. McGreevy with the necessary capital to
enable him to carry out, successfully, his original Contract
with the North Shore, Railway Company, for the construc-
tion and equipment of the Road ; or take the Contract
entirely off his hands, and repay him the amount of his
4 FURTHER STATEMENT OF FACTS.
The second of these Agreements, dated August 1 8th
1875, and after the Railway Company had virtually
abandoned the Road, had reference to the negotiations
then being carried on, between Mr. McG-reevy and the
Provincial Government of Quebec, respecting an entirely
new Contract for the construction of the Road.
The " Statement of Facts, " above referred to, was not
printed until after I had spent several months, in the vain
endeavor to obtain a settlement with Air. McG-reevy, for
the extra services which I had performed in his behalf,
under these Special Agreements ; and until after it had
become clearly evident that he intended to repudiate his
engagements ; and force me either to abandon my claims*
or to resort to such legal remedies as might remain open
My object in printing such a statement at the time, is
fully set forth in the following extract from the " Expla-
natory " remarks, at the commencement of the pamphlet.
" The following " Statement of Facts " in relation # to the
several matters therein referred to, has been compiled with
much care, from originals and copies of letters, documents,
and other memoranda in my possession ; and printed for
the exclusive use and convenience of myself and my
Agents or Attorneys, in the prosecution or disposal of my
claims against the Honorable Thomas McGreevy, M. P.,
and Contractor for the North Shore Railway."
" No general circulation will be given to the document,
by myself at least, either at present, Qr hereafter, unless it
shall be found necessary to do so for the purpose of
vindicating my own private character and professional
reputation, against malicious attacks which may be ma.r^
FURTHER STATEMENT OF FACTS. 5
upon them by interested parties, in advance of a full
development of all the facts in the case, before a Court of
I will now state, with equal frankness, that the present
11 Further Statement of Facts" is published for the purpose
of showing that Mr. McGreevy, in his efforts to free him-
self from his legal, as well as Honorable engagements with
me, has made the most malicious and unwarrantable
attacks upon my private character and professional repu-
tation ; and, also, that the fact of his having done this,
affords me, in my own opinion, at least, the fullest justifi-
cation for giving general publicity, not only to the " State m
ment of Facts " above referred to ; but to the base and
disreputable means which have thus far been resorted to,
by himself and his Attorneys, in their attempts to under-
mine and destroy my own character and reputation, for
the purpose of shielding him from his just and legal obli-
For my rjresent purpose, it will be sufficient to refer to
the " Legal Proceedings, " (which I have also published in
pamphlet form) based upon the Agreement dated August
18th, 1875, of which the following is a true copy, as
acknowledged by Mr. McGreevy himself, in his testimony
in the case.
" Quebec, August 18th, 1875."
" Dear Sir,
In consideration for your extra services, I
hereby agree, that if I close an arrangement with the
Provincial Government of Quebec, by which the Govern-
ment either takes the North Shore Eailway Contract off
my hands, or pays me a cash consideration for performing
6 FURTHER STATEMENT OF FACTS.
the Contract, I will pay you five thousand, dollars upon
the closing of such an arrangement; also five thousand
dollars additional, within one year from that date ; —and
five thousand dollars additional, within two years from
that date ; — making in all, fifteen thousand dollars.
(Signed,) THOMAS McGREEVY.
General Silas Seymour,
Consulting Engineer, &c,
A reference to these Legal proceedings will show, that
my Declaration was dated June 9th 1876, or nearly six
months after the first instalment of $5,000 had become
due under the above Agreement ; and that the suit was
brought for the recovery of this amount, with interest*
It will also be seen, that the Defendant's Answer* dated
July 6th, 1876, contains, substantially, the following allega-
1st. That inasmuch as I was the salaried Officer of the
North Shore Railway Company at the time, any matter or
thing done or performed by me, in connection with said
Railway, was so done and performed, in behalf of the
Railway Company, and not for the Defendant.
2nd. That my continuing to hold office under said Com-
pany, disqualified me from rendering any service to the
Defendant, in connection with said Railway.
3rd. That I acted adversely to the Defendant's interests,
and purposely injured him, both by words and deeds, in
connection with these negotiations with the Government ;
FURTHER STATEMENT OF FACTS. 7
and the subsequent ratification of the Contract, by the
4th. That I never performed any of the services con-
templated, or alluded to in the Agreement of August 18th'
1S75 ; or was willing to perform the same, or any of
5th. That by deceitfully pretending that I had performed
such services ; and concealing from him the fact 4hat I
had acted adversely to the Defendant's interests, I obtained
from him certain payments, to which I ivas not entitled,
and did not earn.
It will be soen from the above, that I am charged by
Mr. McG-reevy with conduct unbecoming to my profession
and official position ; also with double dealing, deceit, pre-
tense, concealment ; and with obtaining money under false
pretenses ; all of which charges and allegations, are to day
and have for several months past, been spread out upon
the pubMc records of the Court, over the signature of his
Attorneys, Messrs Andrews, Caron and Andrews.
I will not pause, at the present moment, to make any
comment upon either the principles, or the animus, which
must have predominated in the mind which dictated
these charges and allegations ; particularly when it was
fully known at the time, that every one of them was
false ; and, as the event proved, not a particle of evidence
was offered in the case, to sustain them ; or to remark upon
the damaging effect which such false and malicious charges
must necessarily have upon my own private character, and
It is proposed, however, to give, in this place, and as a
matter for future, and most important reference, an extract
8 FURTHER STATEMENT OF FACTS.
from Mr. McGreevy's own testimony in the case, for the
purpose of showing the reasons, which at that particular
time, he thought proper to give, under oath, to the Court,
for having signed the Agreement of August 18th, 1875 ;
and also the nature and extent of the extra services referred
to therein, which, at that time, and from his own point of
view, I was expected to perform, under that Agreement.
Extract from the Testimony of Hon. Thomas McGreevy,
given at Enqaete, Oct. 12th, 1876.
" In August and September 1875, I had occasion to have
several interviews w 7 ith the Plaintiff, with reference to the
proposed arrangement about to be entered into *for the
construction of the North Shore Railway by the Govern-
ment; and during this time there were frequent negotia-
tions carried on between me and the Government, to come
to an understanding in the matter.
" One of the principal objects w r as, that the Government
should undertake the construction of the Road, instead of
the Rail w r ay Company ; and another principal object w^as,
to substitute a cash basis for payments, in lieu of Railway
Bonds, and subsidies. It is not true that I, on occasions,
sought the assistance of the Plaintiff ; but he sent for me,
and told me that the Treasurer of the Province had called
on him to assist him in preparing the draft of Contract,
Schedules, and Estimates.
FURTHER STATEMENT OF FACTS. 9
" I was very desirous that the thing should be put
through as soon as possible ; and that there should be no
delay. / signed an Agreement, during these interviews, with
the Plaintiff, upon which this action is based, in order that
there should be no delays, as before stated ; knowing that the
Plaintiff had the means in his power of keeping it back ;
which I would not have done under any other circumstances.
It was not signed for services rendered, and only for the
reason above mentioned."
The following is a copy of the judgment rendered in
th£ above mentioned case, on the 7th of February, 1877 :
Copy of Judgment, in Superior Court, for the first
instalment, under Agreement of August l&th 1875.
" Considering that the Defendant hath failed to prove the
allegations of his plea of Perpetual Exception, in this cause
lyled, the same is hence dismissed.
" Considering that the Plaintiffhath proved the material
allegations of his Declaration ; and more particularly, that
the Defendant, if he closed an Agreement with the Pro-
vincial Government of Quebec, by which the Government
either took the North Shore Eailway Contract oil' his hands •
or paid him a cash consideration for performing the
Contract ; in consideration of the Plaintiff's Extra Services,
agreed to pay the Plaintiff five thousand dollars upon the
closing of such an arrangement ; also five thousand dollars
additional, within one year from that date ; and five
thousand dollars additional, within two years from that
date ; making in all fifteen thousand dollars :
10 FUETIIEK STATEMENT CF FACTS.
" Considering- that the Defendant has closed an arrange-
ment with the said Gov eminent, by which it pays the
Defendant a cash consideration for performing the North
Shore Railway Contract :
" The Court doth adjudge and condemn the Defendant,
for the considerations aforesaid, to pay to the Plaintiff the
sum of Five thousand dollars, with interest and costs. "
Referring the reader to the Pamphlet, hereinbefore men-
tioned, for any farther particulars respecting my first suit
against Mr. McGreevy, under his Agreement of August
18th, 1875, I will now proceed to notice the Legal Pro-
ceedings, so far as they have progressed, under the second
suit, which has been instituted for the recovery of the
second instalment of $5,000 which became due, under the
same Agreement, on the 24th of December, 3S76. Or
within one year from the date of the closing of the arrange-
ment, with the Provincial Government, therein referred
The Plaintiffs Declaration is this case is dated, Quebec
January 15th, 1877, or some twenty days prior to the ren-
dering, by the Court, of Judgment in the first case.
The Defendant's Answer is dated on the 8th of February
1877, or one day after the rendering of Judgment in the first
In order to a perfect understanding of the matter, the
full text of each of these documents will be given, as
Silas Seymour, of the city of Quebec, in the district of
Quebec, Civil Engineer, complaining of the Honorable
Thomas McG-reevy, of the same place, Railroad Contractor,
by this, his Declaration represents :
That the Plaintiff is, and has been for many years, a
General Consulting Engineer, acting as such, more espe-
cially, in so far as relates to the construction and equipment
of Railways, at Quebec and elsewhere.
That the Defendant was, from the 21st of February,
1874, to the 24th of September, 1875, the Contractor for the
construction of the North Shore Railway, then being built
and constructed by the North Shore Railway Company, a
body politic and corporate.
That in the month of August, 1875, the Defendant entered
into negotiations with the Government of the Province of
Quebec, with a view of obtaining from the said Govern_
ment, the Contract for the building of the said North Shore
Railway, on the basis of a cash consideration ; or of being-
relieved from the Contract already entered into for the
construction of the said Railway, which it was then
expected would be taken in hand, and built by the said
12 FURTHER STATEMENT OF FACTS.
That, during the said negotiations, the said Defendant
applied to the Plaintiff, as General Consulting Engineer,
as aforesaid, for his aid and assistance therein.
That, on the 24th of September, 1875, the said negotia-
tions ended ; and a Contract was entered into, between
the Government of the Province of Quebec, and the Defen-
dant, for the construction of the said North Shore Railway,
for a cash consideration to be paid the Defendant for
performing the Contract therein mentioned ; which Contract
was subsequently ratified and approved by the Legislature
of the Province of Quebec, on the 24th December, 1875 ;
and the said Grovernment authorized to carry out the
same ; and to build and construct the said Road.
That, during all the said negotiations, the said Defendant
had the aid, assistance, counsel, and advice of the Plaintiff,
as General Consulting Engineer, as aforesaid ; and that
the Plaintiff rendered the Defendant many and important
services in connection therewith ; all which enured to his
profit and advantage.
That in consideration thereof, the said Defendant, by
paper writing, bearing date at Quebec, the 18th of August
1875, promised and bound himself towards the Plaintiff,
as follows :
" In consideration for your extra services," (to wit, those
above mentioned) " I hereby agree, that, if I close an
" arrangement with the Provincial Government of Quebec,
" by which the Government either takes the North
" Shore Railway Contract off my hands ; or pays me a
" cash consideration for performing the Contract, I will
" pay you five thousand dollars, upon the closing of such
" an arrangement ; also five thousand dollars additional,
plaintiff's declaration 13
** within one year from that date ; and five thousand
u dollars additional, within two years from that date ;
" making in all, fifteen thousand dollars. "
That, in view of the premises, there is due by the
Defendant, to the Plaintiff, the sum of five thousand
dollars ; being the second instalment due under the afore-
said Agreement, or paper writing, and therein mentioned
as the sum of five thousand dollars additional, payable
within one year from the aforesaid date, of the 24th De-
cember, 1875 ; and which said sum, or second instalment
became due and payable, by the Defendant to the Plaintiff*
on the 24th day of December last ; and which said sum the
Defendant refuses and neglects to pay, though often there-
Wherefore, the Plaintiff prays that, by the Judgment of
this Honorable Court, the Defendant be condemned to pay
to him the said sum of five thousand dollars, with interest
and costs, distracted in favor of the undersigned.
(Signed), ALLEYN & CHAUVEAU,
Attorneys for Plaintiff
Quebec, January 15th, 1875,
And the said Defendant, for answer unto the Demande
of him the said Plaintiff, in the Declaration of him the said
Plaintiff in this cause fyled contained, not confessing or
acknowledging any of the matters or things in the said
Declaration set forth alleged to be true, by this his Perpe-
tual Exception Peremptoire en Droit, saith, that the Plaintiff
by Law, cannot at any time have or maintain any action
against the said Defendant, for or by reason of the matters
and things in the said Declaration set forth and alleged, or
of any or either of them, because he says :
That during all the times in which the Plaintiff, in his
said Declaration alleges that he performed services for the
Defendant, he the Plaintiff was a paid officer of the North
Shore Railway Company, receiving as such officer a large
annual salary ; ' and any lawful matter by the Plaintiff,
during the said periods, in relation to or connected with
the said North Shore Railway, or its construction ; or in
relation to the contract for the construction thereof, done
by the Plaintiff, was so done as such paid officer of the
said Company ; and for the said Company, and not for him
the said Defendant, or in his, the said Denfendant's interest.
That the holding, by the Plaintiff, of the said office,
defendant's answer. 15
disqualified him from legally rendering the said Defendant
any services in connection with the said Railroad, its con-
struction, or the contract for its construction ; and in fact
the said Plaintiff did not render the said Defendant any
services, or in any manner advance the interest of the
Defendant in the premises; but on the contrary, acted
adversely ; and opposed his wishes and desires, in reference
to the matters in relation to the Defendant's Contract for
the construction of the said Road, and the ratification by
the Legislature of this Province, of the Contract between
the said Defendant and the said Government.
Wherefore the said Defendant prays the dismissal of the
Plaintiff's action in this behalf, with costs.
And the said Defendant, for further plea to the said
Declaration, saith, that he the said Plaintiff, deceitfully
pretending that he had rendered him, the Defendant,
assistance and services, which in facthe had not, and could,
not lawfully render, obtained from the Defendant a sum
of two hundred dollars, paid by him, the Defendant
to J. Gr. Colston, Esquire, Advocate, at the request, and
upon the written order of him, the said Plaintiff; and
also obtained from him, the Defendant, two negotiable
pormissory notes, dated at Quebec the first of May,
eighteen hundred and seventy-six, for the sum of twelve
hundred dollars each, payable, respectively, three and four
months after their said dates ; and which said notes, he the
said Plaintiff, has negotiated, and received the proceeds
thereof; and never gave any legal consideration for the
And the Defendant avers, that the said notes, and
the said moneys were exacted and given ; and the
16 FURTHER STATEMENT OF FACTS.
letter by the said Defendant signed, dated at Quebec, the
eighteenth day of August in the year one thousand eight
hundred and seventy five, upon which the Plaintiffs
action is founded, and declared upon in his Declaration,
were solicited by the said Plaintiff, and written and con-
sented by the Defendant, and by the Plaintiff received, as
a bribe ; and with the corrupt intention that he, the
Plaintiff, should fail in his duty, as such officer of the said
North Shore Eailway Company, in its relations with the
said Defendant ; and not exact from the said Defendant a
strict and faithful performance of the said Defendant's
contract, as Contractor for the said Eoad.
And the Defendant further alleges, that the Plaintiff did
corruptly obtain from him, the Defendant, the said
writings and promises, with the distinct understanding
between them, that he, the Defendant, would be aided by
him, the Plaintiff, in evading an honest and faithful exe"
cution of his said contract for the said Eailway. And the
said Defendant, yielding to the suggestions of the said
Plaintiff, agreed with him to make him the said several
promises. And he, the said Plaintiff, with the corrupt
view of receiving the amount of the said sums so pro-
mised, undertook to aid and assist him, the Defendant, in
evading a faithful execution of his, the Defendant's con-
tract for the construction of the said Eoad.
And so the Defendant saith, that all the understandings
and promises mentioned in the said Plaintiff's Declaration'
were without legal consideration, and were corruptly and
immorally solicited, exacted, stipulated for, and received
by him, the Plaintiff, as a bribe; and were so by the
Defendant made and given, upon the understanding that
DEFENDANT S ANSWER. 17
he, the Plaintiff, would assist the Defendant, in an unfaith.
ful and imperfect execution of his agreement as Contractor
for the said Railroad ; and are therefore illegal, null, and
All which allegations, the said Defendant doth hereby
aver to be true, and well founded in fact and in law ; and
the same will verify, prove and maintain, when and as
this Honorable Court shall direct.
Wherefore the said Defendant humbly prays that, for
the causes aforesaid, by the Judgment of this Honorable
Court, the action of the said Plaintiff in his behalf, be
hence dismissed with costs ; of which costs, the under-
signed Attorneys, pray distraction in their favor.
Quebec, 8th February, 1877.
(Signed,) ANDREWS, CARON & ANDREWS,
Attys. for Defendant,
FURTHER STATEMENT OF FACTS.
In connection with the latter part of the foregoing
" Answer " by the Defendant, I desire the reader to refer
immediately back to the testimony given under the solem-
nity of an Oath, in relation to the same matter, and by the
same Defendant, on the 12th October, 1876.
In order to bring these remarkable documents face to face
with each other, it will be better, perhaps, to print the
following extracts from each, in parallel columns ; so thai,
like twin productions of the same prolific parentage, they may
become familiar with each others features, and general
characteristics ; for certainly, at first sight, they will not
be able to recognize their uear relationship.
Extract from Mr. McGreevi/s " Testi-
mony. " October \2th, 1876.
" 1 was very anxious that the thing,"
(to wit, the Government Contract),
•' should be put through as soon as
possible ; and that there should be no
delays. 1 signed an Agreement during
these interviews with the Plaintiff, upon
which this actionis based, in order that
there should be no delays, as before
stated, knowing that the Plaintiff had
the means in his power of keeping it
back; which J would not have done
under any other circumstances. It was
not signed for services rendered, and
only for the reason above mentioned. "
Extract from Mr. McGreevi/s " Ans-
wer. " February isth, 187/.
" And the Defendant avers, that the
said notes, and the said moneys were
given ; and the letter by the Defendant
signed, dated Quebec, li<th August,
1875, upon which the Plaintiffs action
is founded, and declared upon in his
declaration, were solicited by the said
P.ainliff, and written and consented by
the Defendant, and by the Plaintiff
received as a bribe ; and with the cor-
rupt intention that he, the Plaintiff,
should fail in his duty, as such officer
of the North Shore Railway Company
in its relations with the said Defen-
dant ; and not exact from the said
Defendant, a strict and faithful per-
formance of the said Defendant's Con-
tract as Contractor for the Road. "
It will be remembered that this Answer was prepared
by the Defendant's Attorney's, and probably at the De-
fendant's dictation, the day after it was known that the
MCGREEVY, Versus MCGREEVY. 19
Court had decided, with reference to the first case : " that
the Defendant hath failed to prove the Allegations of his plea : "
and also " that the Plaintiff hath proved the material allega-
tions of his Declaration;''' and, finally, that: " The Court
doth adjudge and condemn the Defendant, for the considera-
tions aforesaid, to pay to the Plaintiff the sum of Five thousand
dollars, with interest and costs!'
It would certainly, and very naturally be expected, that
a Defence in an exactly similar case ; and prepared under
the immediate negative inspirations of such a decision
from the Court, would contain some points and allegations
upon which to base a last, and most probably a "forlorn
Hope" that were not contained in the Defence to the first
action under the same Agreement; but I must confess,
that, even with my somewhat intimate knowledge of the
Defendant's real character; which knowledge has been
acquired during the past few years of the most painful
and humiliating business intercourse and relations with
him, I was not quite prepared to witness such a degree of
moral obliquity and turpitude, as are exhibited in the above
" Evidence " and " Defence " in this case.
As to how far these remarks will apply to Attorneys, or
Counsel lers at Law, who have deliberately affixed their
signatures to a Defence of the above nature, in the face of
the sworn statements of their own client, I will leave for
others than myself to judge.
The important facts, that for several months previous
to the date of the Agreement in question, I had ceased to
exercise any control whatever, over the character of the
work embraced in the Defendant's Contract with the
Railway Company ; and also, that, at the date of the
20 FURTHER STATEMENT OF FACTS.
Agreement, the "Railway Company had practically ceased to
exist, by reason of having declared its inability to progress
with the work under existing arrangements ; and having
at the same time, invested the Provincial Government
with full power to make such Arrangements with the
Contractor, as it might think proper, in the public in-
terest ; all of which facts, although fully proven, and even
admitted by the Defendant, upon the first trial, seem to have
been entirely forgotten, or intentionally ignored, by the
Defendant and his Attorneys, in the preparation of their
Defence in the second suit, under the same Agreement.
It seems also, to be still more extraordinary, that the Chief
point of Defence set up in the present suit, should have been
entirely forgotten, or intentionally ignored by the Defen-
dant and his learned Attorneys and Counsel, in the Answer
to, and trial of the first suit under the same Agreement.
The further important fact seems also to. have been
entirely overlooked by the Defence, in both cases, to wit :
that in aiding the Defendant in his negotiations with the
G-overnment, the Plaintiff was depriving himself of his
salary as Consulting Engineer of the Road, during its
entire construction ; an equivalent for which, and nothing
more, wa provided for in the Agreement of August 18th
My " Explanatory " to the " Statement of Facts, " herein-
before referred to, closed with the following remarks :
" I will venture to add however, that if the facts as herein
set forth, afford any indication of the nature of the prin-
ciples which have heretofore governed, and still govern the
Honorable Thomas McG-reevy, in his business transac-
tions ; and in his ideas of honesty and fair dealing with
his fellow men, it is a mystery to me, how he has reached
the present exalted social, political, and financial positions
which he claims to enjoy.
" Feeling anxious, if possible, to obtain a solution of this
problem, I shall watch, with more than ordinary solicitude,
the result of the application of the same principles, as
already initiated, in the carrying out of the great and
important Undertaking, with which he has been entrusted
by the Provincial Government. "
I will now close the present " Further Statement of Facts"
with only the additional remarks ; that I shall continue to
watch with equal, if not greater solicitude, the result of the
application of the same, or if possible, more corrupt prin-
ciples, as already not only initiated, but fully developed
by Mr. McG-reevy, in his repudiation of his solemn Agree-
ment of August 18th, 1875.
22 FURTHER STATENENT OF FACTS.
I have always had an abiding, and I humbly trust, a
religious faith, in the doctrine of retributive justice ; and also,
in the doctrine of future, and, to a certain extent, of present
rewards and punishments. But I will frankly confess, that
if the course taken in this matter, by the Honorable Thomas
McGTreevy, M. P., and Government Contractor for the North
Shore Railway, shall prove successful on his part ; and
at the same time destructive, as it must consequently prove*
to my own private character and professional reputation ;
my faith will be very considerably shaken, as to the theory
of present rewards and punishments ; but it will, at the
same time, be very much strengthened, as to" the nature
and extent of the rewards and punishments, that are quite
sure to be meted out, in that future world, to which we are.
all so rapidly, and so certainly hastening.
If Mr. McG-reevy chooses to continue to occupy the
position of a prominent party to a gigantic scheme of bribery
and corruption, such as his Attorneys aver, and solemnly
declare, in his Answer, that he is able to prove before the
Court, at any time when called upon to do so, I shall
certainly not object ; but he must excuse me from volun-
tarily accompanying him down to these depths of infamy
Feeling, as I sincerely do, an abiding consciousness of
having, in the most perfect honor and good faith, performed
all, and even more than I undertook, or than Mr. McG-reevy
could have expected me to do, under the Agreement in
question; and that in doing this, I not only benefitted
him to the extent of several hundred thousand dollars ;
but also carried out, to the fullest extent, the expressed
wishes and desires of the Railway Company, whose servant
CONCLUDING EEMARKS .23
and salaried officer I was ; while/at the same time, I acted
in the most perfect good faith towards the member of the
Provincial Government, who was conducting the nego-
tiations with Mr. McGreevy, I shall most certainly continue
my efforts to obtain such justice from him. as the laws of
the land will accord to me ; not only for the services which
I rendered to him under the Agreement in question ; but
also for the great damage which he has inflicted upon me,
by reason of his fraudulent representations, in connection
Even during the short space of time that has already
intervened, since these atrocious calumnies have been
spread upon the public records of the Court, they have
been caught up by the news-paper Press, and spread
through the entire country like wild- fire ; accompanied by
comments and remarks, that are calculated to, and must
necessarily inflict an irreparable injury upon my personal
character, and professional reputation ; which are now<
and always have been my only working capital ; and
without which, pure and usullied, no Civil Engineer can
hope for success in his Profession.
By immediately supplying the Press, and the leading
business men of this Country, the United States, and
Europe, with a well authenticated " Statement of Facts " in
the case, I may perhaps counteract the evil to some extent ;
but it never can be fully remedied.
General Consulting Engineer.
Quebec, February 17th 1877.
LATEST EDITION OF FACTS,
" 4 few more of the same sort left."
Inasmuch as events have occurred, since the foregoing
" Statement " has been put in type, which may have an
important bearing upon the matter. I have felt it my duty
to stop the Press, for the purpose of placing before the
Public, the latest " Facts " in this most remarkable Case.
After I had respecfully declined to accede to any terms
of settlement with the Honorable Thomas McG-reevy, that
did not recognize his full obligation to carry out his
Agreement of August 18th 1875 ; and also a full and un-
qualified retraction by him, of all his slanderous allega-
tions against me, in connection therewith :
And after the Defendant had been served with a notice
to appear in Court, on Monday morning, February 19th,
1877, and answer certain interrogatories, [Fails et Articles)
with which he was furnished, in relation to the truthful-
ness or falsi lj/ of the allegations contained in the Plaintiff's
Declaration, and the Defendant's Answer, in the Case now
And after it had become generally known, that 1 was
preparing the foregoing " Further Statement of Facts 1 ', for
the purpose of placing all these matters in their true light
before the Public; and thus counteracting, as far as possi-
ble, the injury which I was sustaining from the general
circulation of his libellous calumnies, against my private
character and professional reputation :
And after I had sent to the Editor of the Quebec " Morn-
ing Chronicle, " the following communication upon the
" Sir, — I have observed in a recent issue of the Chronicle ;
and also in the Montreal and other papers, allusions to
the matters in difference between Mr. McGrreevy and
myself, respecting the North Shore Eailway ; all of which
are calculated to injure my private character and profes-
" May I ask that the Chronicle, and other papers
throughout the country, w T ill kindly refrain from any fur-
ther remarks of this nature, until I can furnish to the Press,
and the Public generally, a w T e!l authenticated " Statement
of Facts" in the case; which I hope to have ready for
general circulation, within a day or two.
General Consulting Engineer. "
Quebec, Feb. 17, 1877.
After the occurrence of the above mentioned events, it
appears to have been suddenly discovered by the Honorable
Thomas McGreevv, M. P., and Government Contractor for
LATEST EDITION OF FACTS. 3
the North Shore Railway, that his Parliamentary duties
imperatively required his immediate presence in Ottawa,
the Capital of the Dominion.
The Local column of the Quebec " Morning Chronicle" of
Monday, Feb. 19th, 1877, therefore contained the following
important item of information :
" Personal. — Hon. Mr. McGreevy, M. P. for Quebec
"West, was to have left for Ottawa on Saturday evening, to
attend to his sessional duties."
The Editorial column of the same paper, was also headed
with the following double-leaded, and startling announce-
** We are authorized by Mr. McGrreevy to state, that the
plea fyled in the Court House, and alluded to in the Press,
was not authorized by him, and was done without his
knowledge or consent."
When the Case of Seymour versus McGreevy, was called
in the Superior Court, at half past ten, on the same
eventful Monday morning, Mr. F. W. Andrews, Q. C, of the
Law Firm of Andrews, Caron and Andrews, a fine venerable
looking G-entleman, who I am assured, wrote the " Plea
fyled in the Court" to which allusion is made in the above
News-Paper Editorial ; and whom, I know, heard, and paid
the closest attention to every word of his Honorable Client's
testimony, as given at Enquete on the 12th Oct., 1876, in
the first suit, and under the same Agreement; which
testimony, as has already been shown, belies £the entire
latter portion of the Plea : This G-entleman, after having,
as I am credibly informed, consulted fully with his asso-
ciate Counsel in the Case, arose in response to the above
call, and applied to the Honorable Court for a postponement
of the Case, upon the ground that the rule which had
been personally served upon Mr. McG-reevy, three days
previously, ordering him to answer certain interrogatories
therein mentioned, had issued prematurely ; by reason of
which, he had taken the responsibility of advising his
Honorable Client, that it was his privilege and duty to obey
the call of his Country, instead of ihe Summons of the Court;
and that the Expected Witness had consequently left for
After a most scathing and earnest argument and pro-
test, by Mr. E. Alleyn, Q. C, of Messrs. Alleyn and Chau-
veau, my own Attorneys, the Honorable Court thought
proper to postpone a further hearing in the Case, until
March 9th, 1877.
If it had been the desire or intention, of the Defendant
to make any responsible denial, or explanation of the
calumnious Plea in question, with a view of shielding
himself from the responsibilities connected therewith ;
and at the same time, protecting me, as far as it was then
possible, from further injury therefrom ; it is quite evident
that he had been furnished, by my oivn Attorney, with a
most favorable opportunity of doing so, by appearing in
Court, and answering the interrogatories which had pre-
viously been propounded to him.
Instead of doing this, however, it will be seen, that by
the deliberate and concurrent action of the Honorable
Defendant, and his learned and venerable Attorney, and
Counsel, I am compelled to rest, so far as the records of
the Court are concerned, for several weeks to come, under
the public charge and allegation of having been a party,
LATEST EDITION OF FACTS. 5
with the Honorable Thomas McGrreevy, M. P., and Govern-
ment Contractor for the North Shore Kail way, to a vile con-
spiracy to defraud my employers ; and also of having- corruptly
accepted a bribe, for the same dishonorable purpose.
Eeferring a moment, however, to the most extraordinary,
and totally irresponsible announcement contained in the
Editorial column of the " Morning Chronicle^ above re-
ferred to, it would appear, that the celebrated Plea, or
Answer in question, has been placed in a most anomalous*
if not embarrassing position.
If any reliance is to be placed in the Newspaper Editorial^
above referred to, this Plea has been driven from the
protecting roof of its reputed Father, or God-Father, which-
ever he may be ; and the poor Bantling, or Orphan, is now
wandering about, like " Japhet in search of a Father " ; or
perhaps, more legally speaking, like a Defence in search of a
Defendant, in the vain endeavor to induce some kind
hearted and charitable individual, to afford if shelter and
Feeling as I do, a great interest in this poor and
forsaken Outcast ; notwithstanding it has been the cause
of the deepest injury to me, I will, if such shall prove to
be the case, be most thankful to any responsible party
who will either acknowledge its paternity ; or furnish
such reliable information as will lead to their early dis-
So far as I am personally concerned, however, the
Honorable Defendant, and all parties in interest, may rest
assured, that no News-paper Editorial ; nor any legal quibble,
which either he, or his Attorney, and Counsel may pro-
mulgate, or resort to, will divert me from my settled purpose
to pursue this whole matter to its legitimate conclusions ;
under the full conviction that :
" Thrice armed is he whose cause is just."
Quebec, February 20th, 1877.